https://www.taxtmi.com/caselaws?id=770603 ITAT Delhi ruled in favor of the assessee regarding reopening of assessment under section 147. The AO alleged bogus transactions in penny stock shares based on information from other cases, without establishing the assessee's involvement as beneficiary. The tribunal found no basis for the AO's allegations, noting the assessee had closing stock of 16,155 shares which was incorrectly included in sale calculations. Since the transactions were previously accepted under section 143(3), the fresh allegations constituted mere change of opinion rather than new material. Appeal allowed. en-us Fri, 02 May 2025 00:00:00 +0530 Wed, 14 May 2025 07:48:05 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=770603 ITAT Delhi ruled in favor of the assessee regarding reopening of assessment under section 147. The AO alleged bogus transactions in penny stock shares based on information from other cases, without establishing the assessee's involvement as beneficiary. The tribunal found no basis for the AO's allegations, noting the assessee had closing stock of 16,155 shares which was incorrectly included in sale calculations. Since the transactions were previously accepted under section 143(3), the fresh allegations constituted mere change of opinion rather than new material. Appeal allowed. Case-Laws Income Tax Fri, 02 May 2025 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=770603